BEPS and anti-abuse rules: The EU law dimension

Introduction

The Organisation for Economic Co-operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project has been creating considerable debate and discussion in the international tax community.

Double Taxation, Transfer Pricing, Anti-Avoidance, Withholding Taxes

The intergovernmental agreement between the US and the UK for the implementation of FATCA: Part II

In Part I, Angelica Maria Orozco Diaz analysed the Intergovernmental Agreement between the USA and the UK in relation to FATCA. She continues her discussion here.

Anti-Avoidance, US/Americas

BRICS and article 12: international tax policy implications: Part 4

In this final part, Peter Wilson concludes his discussion of Article 12. Parts 1-3 appeared in the previous three issues of ITR.

Double Taxation, ROW

Is cloud computing a challenge to the traditional concept of a permanent establishment?

The term cloud is used by the information and communication technologies (ICT) industry to indicate, primarily, virtual platforms or infrastructures that allow the execution of codes (services, applications, among others) in various forms across multiple resources, with relevant data.

Region, Europe
Corporate Taxes

Is cloud computing a challenge to the traditional concept of a permanent establishment?

Part 3

In Parts 1 and 2, which appeared in the March and April issues, Maria Cecilia Rossi discussed Cloud Computing and its interaction with the concept of permanent establishment. Here, in Part 3, she concludes her discussion.

Corporate Taxes, Practice
Anti-Avoidance

The intergovernmental agreement between the US and the UK for the implementation of FATCA

Introduction

A global consensus against harmful tax competition practices and tax evasion has traced a pattern among the tax policies of many countries in the world embracing automatic exchange of information.[1] Since 2003, the Organization for Economic Cooperation and Development (OECD) has been promoting the automatic exchange of information both by multilateral co-operation between states and bilateral tax treaties[2]; this practice has been followed by the US with a most remarkable measure, ie, the Foreign Account Tax Compliance Act 2010 (FATCA) which is an attempt by the US government to force foreign financial institutions (FFIs)[3] into compliance with the automatic exchange of information.[4]

Anti-Avoidance, US/Americas
Region

Latest developments in the German tax treaty policy

Germany has a wide tax treaty network containing more than 90 tax treaties. Tax treaty negotiations are generally based on the OECD Model Tax Convention and with respect to developing countries on the UN Model Tax Convention.

Double Taxation, Europe
Double Taxation

Is cloud computing a challenge to the traditional concept of a permanent establishment? Part 2

In Part 1, Maria Cecilia Rossi introduced the concept of cloud computing and examined its interaction with traditional international tax law concepts and theories, with particular reference to the concept of permanent establishment. In Part 2, Rossi continues this discussion.

Corporate Taxes, Double Taxation
Investment and Indirect Taxes

Investment in Colombia from an international taxation perspective: Part 2

In Part I, Sylvia H. Torres Caro discussed how Colombia attracts foreign investment and focused her discussion on legal stability agreements put in place by Colombia and other Latin American countries. She concluded by briefly discussing the role played by Colombia’s double tax treaties in securing foreign direct investment. Part II continues this discussion.

Investment and Indirect Taxes, US/Americas
Practice

International tax avoidance using trusts: How can Cyprus facilitate this form of tax planning?– Part II

In Part I, Iva Angelova introduced the concept of tax avoidance and explained how trusts are used in tax planning schemes. In Part II, she continues with a discussion on the use of trusts internationally and the role played by Cyprus in the world of tax planning.

Anti-Avoidance, EU Law